Rulings and Tax Opinions
We offer highly specialized tax, distribution consulting and other services to all types of clients. We provide taxpayer representation services required by tax audits, notice responses and other administrative matters. We advise lawyers and litigants on the tax issues raised by settlements, judgments, enforcement actions and funds of money established to resolve claims. We provide private letter and other rulings and prepare tax opinions for individuals, businesses, public agencies, foundations, trusts and fiduciaries.
- Project Management
- Litigation Support
- Private Letter Ruling Requests
- Tax Opinion Preparation
- Closing Agreements
Client: U.S. Securities and Exchange Commission
Issue: The SEC sought our assistance in determining the tax reporting issues arising out of distributions to injured mutual fund investors from Fair Funds established by the Sarbanes-Oxley Act of 2002.
Results: Our team, led by Julia Damasco and including Nicholas Sanchez and Jude Damasco obtained nineteen favorable private letter rulings from the National Office of the Internal Revenue Service addressing the information reporting obligations of Fair Funds established by the SEC to compensate injured investors. They prepared informational tax letters consistent with private letter rulings for publication on websites and for the benefit of injured investors.
Client: National Mortgage Qualified Settlement Fund administered by claims administration firm and established by the Attorneys General in 49 states
Issue: Client sought our assistance in determining the tax reporting obligations of a qualified settlement fund established as part of the National Mortgage Settlement to compensate borrowers who suffered financial injury arising out of home foreclosure process by the country’s five largest mortgage servicers in the wake of the mortgage crisis. Settlement provided over $50 billion in relief to distressed borrowers and payments to states and the federal government.
Result: Provided advice to the Executive Committee of the Attorneys General and engaged in discussions with the United States Department of the Treasury, resulting in a Revenue Ruling providing uniform guidance and relief to all taxpayers. Rev. Rule 2014 – 2.
Client: Microsoft Temporary Workers
Result: We obtained a Closing Agreement providing favorable tax treatment for payments made to class members.